G. SIVARAJAN, J.

The matter arises under the Kerala General Sales Tax Act, 1963. The petition is an abkari contractor. He is an assessee to sales tax under the Act. There was an inspection in the business premises of the petitioner by the Intelligence Squad, Thiruvananthapuram on June 6, 1988 and they verified the physical stock of certain items found there. Later, the Intelligence Officer, Squad No. I, Thiruvananthapuram (first respondent herein) verified the accounts of the petitioner with reference to the physical stock found on inspection and issued a notice to the petitioner stating that he has failed to maintain true and complete accounts of his business during the year 1988-89 for which he is liable for penal action under section 46 of the Kerala General Sales Tax Act, 1963. He was also called upon to show cause why prosecution steps should not be initiated against him. At that point of time the petitioner approached the first respondent with an application for compounding the offence departmentally under section 47 of the Act, wherein he has offered to compound the offence pointed out in the notice for a sum not exceeding Rs. 50,000. The first respondent accepted th